Determining whether a taxpayer is capitalizing
a particular cost under Sec.
However, in three at least, capitalizing
the pronoun was presented as optional.
As I expected, the Stylebook called for capitalizing
internet, but its definition of the word seemed to favor my interpretation: "A decentralized network of host computers that are linked by high-speed lines."
interest to a long-term contract will have a measurable impact on taxable income only where interest incurred fluctuates widely from year to year, though, typically this will not happen where a substantial portion of a business is devoted to U.S.
16 says entities that engage in purchase acquisitions may include certain associated costs in the acquisition price, thereby capitalizing
the costs rather than deducting them from income as an expense in the current period.
The new final regulations on capitalizing
intangibles clearly would not apply to the years at issue in Chief Industries; see Regs.
The procedures generally are consistent with the existing procedures for automatic accounting-method changes; however, following the issuance of an advance notice of proposed rulemaking on capitalizing
costs incurred as to intangible assets (NPRM REG-125638-01, 1/24/02), some taxpayers changed to accounting methods provided in the final regulations without IRS consent.
1.263(a)-4(f)(vi), an accrual-method taxpayer must still wait until a liability is incurred before capitalizing
or deducting prepayments.
1998), an appeals court held that a utility's change from capitalizing
to expensing fuel costs did not represent a change in accounting method.
Presumably, the financial accounting standard of capitalizing
these costs drew the Service's attention, as it provided a convenient argument and numeric support for applying these capitalization principles for tax purposes.
Taxpayers currently capitalizing
ISO 9000-related costs, who want to change to the method described in Rev.
97-35 goes to great lengths to describe the Service's position on capitalizing
and amortizing package design costs.